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    Digging in to Benchmark Plan Details

    Eager to dig into details about state benchmark plan choices so far? This chart provides key details—with direct links to evidence of coverage documents and CCIIO’s plan summaries—about the plans states have selected or defaulted into. States had until December 26, 2012 to submit comments on the proposed EHB regulations to finalize their benchmark plan decision. For background, see our blog post.

    Like all State Refor(u)m research, this chart is a collaborative effort with you, the user. State Refor(u)m captures the health reform comments, documents, and links submitted by health policy thinkers and doers all over the country. And our team periodically supplements, analyzes, and compiles this key content.

    Know of something, like an additional evidence of coverage document, we should add to this compilation? Eager to update a fact we've included? Your feedback is central to our ongoing, real-time analytical process, so tell us in a comment below, or email the author with your suggestion. She can be reached at

    *Chart updated on February 5, 2014

    StateRecommendation to HHSSmall GroupLargest HMOState EmployeeNational FEHBPDefaultEvidence of CoverageCCIIO Plan SummariesPediatric VisionPediatric Oral
     Selection of a benchmark plan whose benefits will largely define "essential health benefits"HHS Bulletin, FAQ and final regulations defined options from which states could choose a benchmark plan If a state does not choose a plan, its benchmark is set by default as the largest small group market product in the state's small group market  The Benchmark plan's coverage details and contract with policyholdersBenchmark plan's summary available at CCIIO

    HHS requires benchmark plans to meet all 10 essential health benefit categories including pediatric vision and oral health care services. Many existing commercial plans do not offer pediatric vision or pediatric dental, so states are required to choose a supplemental plan that covers these services.

    Blue Cross Blue Shield of Alabama
    PPO 320 Plan
    Premera Blue Cross Blue 
    Shield of Alaska 
    Heritage Select Envoy PPO
    Arizona Benefit 
    Options EPO Plan, 
    administered by United HealthCare
    ARHMO Partners, Inc. Open Access POS, 13262AR001X    XX2FEDVIPCHIP
    CAKaiser Foundation Health Plan Small Group HMO 30 ID 40513CA035X    XX CHIP
    Kaiser Foundation 
    Health Plan of 
    Colorado Ded HMO 1200D
    X    XX CHIP
    Highmark Blue Cross Blue 
    Shield Delaware  Simply Blue 
    EPO 100 500
    DCGroup Hospitalization and Medical Services, Inc. BluePreferred PPOX    XXFEDVIPFEDVIP
    Blue Cross 
    Blue Shield of Florida, Inc. BlueOptions 5462
    Blue Cross Blue Shield of Georgia
    HMO Urgent Care 60 Copay
    Hawaii Medical Service Association  Preferred 
    Provider Plan 2010
    Blue Cross of 
    Idaho Health 
    Service, Inc. 
    Preferred Blue PPO
    Blue Cross and Blue Shield of Illinois 
    BlueAdvantage PPO
    Anthem Blue 
    Cross and Blue 
    Shield of 
    Indiana Blue 5 Blue Access 
    PPO Medical Option 6 Rx Option G
    Wellmark Inc.
    Alliance Select
    Copayment Plus PPO
    Blue Cross and Blue Shield of Kansas 
    Comprehensive Major Medical Blue 
    Choice PPO GF 500 deductible with Rx card
    KYAnthem Health Plans of Kentucky, Inc. PPO X    XX CHIP
    Blue Cross and 
    Blue Shield of 
    Louisiana GroupCare PPO
    Anthem Health 
    Plans of Maine
    Blue Choice 
    20 PPO with 
    RX 10 30 50 5
        X X FEDVIP
    CareFirst BlueChoice HMO HSA Open Access Plan4
    Blue Cross and Blue Shield of Massachusetts, Inc. HMO Blue, 2000 DeductibleX    XX CHIP
    Priority Health PriorityHMO100 Percent Hospital  Services Plan
    500 25 Open 
    Access PPO
    MSBlue Cross and Blue Shield of Mississippi Network Blue PPOX    XXFEDVIPCHIP
    Healthy Alliance Life Insurance Co. 
    (Anthem BCBS) 
    Blue 5 Blue Access PPO 
    Medical Option 4 Rx Option D
    Blue Cross and 
    Blue Shield of 
    Montana Blue 
    Dimensions PPO
    NEBlue Cross and Blue Shield of Nebraska BluePride PPO    X XFEDVIPCHIP
    NVHealth Plan of Nevada Point Of Service Group 1 C XV 500 HCRX    XXFEDVIPCHIP
    Matthew Thornton  Health Plan (Anthem BCBS) 
    HMO Blue New England 25 50 WITH Rx 10 35 30 OOP 2500
    Horizon HMO 
    Access HSA 
    NMLovelace Insurance Company Classic PPOX     X CHIP
    NYOxford Health Insurance, Inc. Oxford EPOX     X CHIP
    Blue Cross and 
    Blue Shield of 
    North Carolina
    Blue Options PPO
    NDSanford Health Plan HMO X   XXCHIPCHIP
    Community  Insurance 
    Company (Anthem 
    BCBS) Blue 6 Blue 
    Access PPO Medical Option D4 Rx Option G
    Blue Cross and 
    Blue Shield of 
    PPO RYB05
    Health Plans 
    PPO Preferred 
    CoDeduct Value 3000 35 70
    Aetna Health, Inc.
    PA POS Cost 
    Sharing 34 1500 Ded
        X X FEDVIP
    RIBlue Cross and Blue Shield of Rhode Island Vantage Blue PPOX    XXFEDVIPFEDVIP
    Blue Cross 
    Blue Shield of 
    South Carolina
    Business Blue 
    Complete PPO
    SDWellmark of South Dakota Blue Select PPOX     XFEDVIPFEDVIP
    Blue Cross 
    Blue Shield of 
    Blue Cross 
    Blue Shield of 
    Texas BestChoice  PPO RS26
    Public Employee’s 
    Health Program
    Utah Basic Plus
      X  XX  
    The Vermont Health Plan, 
    VAAnthem Small Group PPOX     XFEDVIPCHIP
    Regence BlueShield 
    small group product
    Highmark Blue 
    Cross Blue 
    Shield West Virginia Super Blue 
    PPO Plus 2000 
    1000 Ded
    UnitedHealthcare Insurance 
    Company Choice Plus Definity HSA Plan A92NS
    Blue Cross 
    Blue Shield of 
    Blue Choice Business 1000 
    80 20
    Total 205302324 42 FEDVIP, 2 CHIP, 7 Included26 FEDVIP, 24 CHIP, 1 Included



    1Alaska supplemented their plan with FEHBP. 

    2Arkansas supplemented their plan with FEHBP. 

    3In their comment letter to HHS on the final interim rule for standards related to essential health benefits, Kansas revised their supplemental pediatric vision and oral plans to the Kansas Children’s Health Insurance Plan (CHIP) benefits. 

    4Maryland revised its EHB Benchmark Plan selection.

    5New Jersey chose the largest HMO plan to serve as their EHB benchmark and designated NJ FamilyCare (CHIP) as the supplemental pediatric oral plan.


    Chart produced by: Jade Christie-Maples and Kaitlin Sheedy

    Related categories: 


    I would love to hear how states share how they are approaching the issue of "habiltiative benefits" - over 20 states in the proposed rule chart were listed as having habilitative benefits, yet the HHS guidance has repeatedly said habiltiative is not a common coverage category. Are states attempting to define these benefits, or deferring to carriers? If a state has habilitative benefits in its benchmark, what scope do they have?

    RI was one of the few states to admit it did not cover habilitave benefits. We have given the following guidance to plans in the form of a draft regulation about how to comply with new aca consumer protections, including ehbs -

    A key addendum to the reg is a check list to be used by the plans when submitting and by us when reviewing. The check list is not part of the reg so we can update it. In that check list are our specific directions for EHB, including hab services. We have asked the plans to define hab services with the following guidance:
    - have evidence-based coverage guidelines for hab services, not scope and duration limits.
    - if you can;t do that, submit a memorandum to say why not.
    - provide actuarial memorandum demonstrating the estimated costs of hab benefit are not less than estimated cost of rehab benefit in bench mark plan.

    We will review submissions and consider

    This is an attempt to meet stakeholder feedback which included
    - no unlimited habilitative services benefit.
    - no arbitrary scope and duration limits,.

    No questions from the plans so far or stakeholders - could be because they are swam;ed with other things. It will be interesting to see what they submit.

    hope this helps

    Chris Koller

    In CA we worked with numerous stakeholders to develop a definition for habilitative services, which I've posted below. California believed it was critical for the state to define a uniform definition to be used by carriers and not have each carrier attempt to create a separate definition. Happy to answer any questions.

    Katie Trueworthy
    Senate Health Committee

    Habilitative services" means medically necessary health care services and health care devices that assist an individual in partially or fully acquiring or improving skills and functioning and that are necessary to address a health condition, to the maximum extent practical. These services address the skills and abilities
    needed for functioning in interaction with an individual's environment. Examples of health care services that are not habilitative services include, but are not limited to, respite care, day care, recreational care, residential treatment, social services, custodial care, or education services of any kind, including, but not
    limited to, vocational training. Habilitative services shall be covered under the same terms and conditions applied to rehabilitative services under the policy.

    Has anyone tracked how many states submitted comments or updates to their EHBs to CCIIO? I am aware of MD selecting a new EHB Benchmark, OH submitted a letter on Habilitative Services (, and CO also submitted a comment letter - which also defined Habilitative Services ( Just wondering if there were other comment letters out there.

    Hi Dustin,

    In addition to the letters you mentioned, we have also found letters from Kansas and Arizona that address the issue of habilitative benefits.

    The letter from Kansas indicates that because their EHB benchmark has well-defined rehabilitative services, they will require participating plans to offer habilitative services in parity with rehabilitative ones. Kansas expects that this will ensure consistency across plans offered in the state. You can find the letter here:

    In their comments on the interim final rule, Arizona requested that states be permitted extra time to define habilitative services in their benchmarks. See here for their comments:

    In addition, New Jersey submitted a comment letter selecting the largest HMO plan in the state to serve as their benchmark. You can find that here:

    I hope this helps. We would love to hear from other states that can share their own comments on the final EHB rule.

    Arkansas has developed some great materials on the issue of habilitative benefits. Although their conversation is ongoing, here’s their latest presentation and the draft language they’ve developed so far. AR’s Steering Committee approved language in December defining habilitative benefits to be “services provided in order for a person to attain and maintain a skill or function that was never learned or acquired and is due to a disabling condition” including “physical, occupational and speech therapy provided for developmental delay, developmental disability, developmental speech or language disorder, developmental coordination disorder and mixed developmental disorder.”

    The Steering Committee has deferred to the Plan Management Committee to further define specific services to be covered under this essential health benefit.


    Draft Language:

    Could someone double check the totals at the bottom? I have scrolled up and down several times and not found the "1" in the National FEHBP column. If one column is wrong, others may be as well.

    If the chart is maintained as an Excel sheet, you may wish to use a formula to keep the totals accurate. For example =COUNTA(F3:F53) would count non-blank cells, unless your blank cells contain null strings. To count the number of cells containing at least the letter "x" you could use =COUNTIF(F3:F53,"*x*"). A more intricate option would be =SUM(LEN(F3:F53)>0) ; because it is an array formula, you need to hold down shift and ctrl while pressing enter or it will generate an error.

    People here seem genuinely appreciative of sound data, so I am confident my comment will be taken in the spirit it is intended, even if it looks like a techie side note.

    All the information I've read on EHBs notes that states will have to supplement their benchmark plans with categories from other plans if they are missing one of the 10 essential coverage areas. I can't find these supplemental plans anywhere. Have states simply not submitted them yet or am I looking in the wrong places? I am trying to survey benchmark plans' mental health coverage but don't think I can get a true idea of whether there is equitable coverage unless I review supplemental plans as well. If you could help clarify this issue I'd appreciate it! Thanks.

    Hi Jeanene, Thank you so much for your question. Generally, we have found information on state benchmark decisions and specific evidence of coverage documents on their Insurance Department and/or exchange websites. The specific supplement plans are listed in the CCIIO plan summaries we’ve linked to above. From what we know, only Alaska and Arkansas supplemented the mental health benefit coverage in their benchmark plan. I was able to access Arkansas’s FEHBP supplement for mental health coverage (see page 45, You can find all links to their benchmark selection process here:

    Hi Jade & Kaitlin, Could you please tell me if the ACA final regulations for 2014 will finally eliminate the division between mental health benefits and medical health benefits? In other words, will all health insurance policies be required to provide full mental health benefits in 2014? We have suffered for many years with the lack of (or strong limitations on) mental health insurance benefits here in Texas. Will this unfortunate, but clear division between these medical and mental health benefits finally disappear in 2014?

    Hi Jerry, The final regulations on Essential Health Benefits require qualified health plans that will be sold through an Exchange and plans that will be sold in the individual and small group market to comply with the Mental Health Parity and Addiction Equity Act. That means that plans must provide mental health and substance use disorder benefits, and they cannot impose limitations on the duration of treatment (number of visits,lengths of stay) or financial requirements (cost sharing) that are more restrictive for these services than for medical services. The Parity Act standards should also require carriers to provide a continuum of services for mental health/substance use disorders that is comparable to medical services, although the federal agencies have not yet issued a final ruling on this "scope of services" question. Coverage for mental health services should improve in Texas. However, I noticed that the Texas benchmark plan includes restrictions on the number of days of care that will be covered for mental health outpatient and inpatient care. It also limits the number of lifetime treatment admissions for addiction treatment. These limitations most likely violate the Parity Act, and health plans should not be able to impose these restrictions. You should contact the Texas insurance department and request that it enforce the Parity Act.

    The January 16, 2013 State Health Official/State Medicaid Director letter re Application of the Mental Health Parity and Addiction Equity Act to Medicaid MCOs, CHIP, and Alternative Benefit (Benchmark) Plans may also be of interest:

    Can anyone please tell me whether Medical Foods and Formula, used for the treatment of inborn errors of metabolism, were included as Essential Health Benefits?

    Hi Rachel,
    This is a really good question. Like most essential health benefits (EHB) questions, it doesn’t have a uniform “yes or no” answer because each state has a different “benchmark” or model plan upon which its EHBs were built. (For more details about the EHB benchmark approach, see “Your Questions about the EHB Bulletin Answered” from the Catalyst Center at Boston University - In some states, coverage for medical foods and formulas are in the benchmark plan because the issuer included it or, more likely, because there’s a state mandated benefit law on the books requiring it. In other states, medical foods and formulas are not included. In Missouri, state law requires coverage for formula and low protein modified food products for patients under age six with PKU or other inherited diseases of amino and organic acids. Here’s a link to the statute so you can see the details: Because this state mandated benefit law applies to the benchmark plan, it’s my understanding it’s included along with the limits described in the statute. For folks in other states who are interested in learning whether or not a specific benefit or service is included in their benchmark plan, go to the Center for Consumer Information and Insurance Oversight (CCIIO) website at – you can look up your own state’s benchmark plan details and state mandated benefit laws there. One caution- the information on the CCIIO site is short and summarized, so going to the actual statute or plan for the details is recommended. Hope this is helpful - Meg

    Is it possible to review and possibly refresh the Benchmark Plan table with more current information? The "Chart updated" date reflects March 18, 2013.

    Some of the reporting in the “Pediatric Oral” column may be out of date. Could the following points be updated and the totals along the bottom be updated to reflect these? Delaware, Nevada, Oklahoma, Virginia and West Virginia designated the state CHIP program (not FEDVIP) as the supplemental benchmark for pediatric oral services. Feel free to reach out with questions on these and thanks for all the great resources on Statereforum!

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